In the 1923 case of Anderson v. Corall, the U.S. Supreme Court ruled in favor of Warden Anderson, reversing a lower court's decision to grant habeas corpus relief to prisoner Corall. The issue at hand was whether or not Corall had been denied his constitutional right to due process when he was convicted for violating the Espionage Act during World War I without being provided with counsel. The Supreme Court held that since Corall did not request an attorney and there were no complex legal issues involved in his trial that would necessitate one, his Sixth Amendment rights were not violated by proceeding without counsel. Therefore, it concluded that he was lawfully detained under federal custody and reversed the order granting him release via writ of habeas corpus.

In the dissenting opinion for Anderson v. Corall, Justice McReynolds disagreed with the majority's decision to grant habeas corpus relief to a prisoner who was serving consecutive sentences. He argued that when a court imposes multiple sentences to run consecutively rather than concurrently, it is within its rights and discretion under federal law. The judge believed that each sentence should be viewed as separate and distinct from one another, not as part of an aggregate punishment exceeding what would otherwise be permissible for any single offense committed by the defendant. Therefore, he contended that there was no legal basis or justification for allowing prisoners like Corall to challenge their cumulative punishments on grounds of excessiveness or disproportionality in relation to their crimes.